AMLCC is committed to protecting the privacy and security of your personal data.
1. What is the purpose of this document?
This privacy notice describes how we collect and use personal data about our customers, suppliers and other third parties, in accordance with UK data protection law, and provides you with information about your privacy rights and how the law protects you. This privacy notice applies to all personal data we process regardless of the media on which that data is stored or whether it relates to past or present customers, clients, supplier or contacts.
2. The Controller
For the purposes of UK data protection law, Anti-Money Laundering Compliance Company Limited (AMLCC) is the “controller” and responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
If you have any questions about this privacy notice, or would like to exercise your rights as described herein, please contact us using the details set out in paragraph 16 below.
3. The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and/or payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. How is your personal data collected and used
We use different methods to collect data from and about you, either directly or indirectly (e.g. from third parties or by automated means such as cookies).
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, by corresponding with us by post, phone, email, via our website or otherwise, or when you enter into a contract with us for the provision of our services.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, namely: your employer (if they set up a user account for you), a mutual contact who may refer you to us, website analytics providers (e.g. Google Analytics), credit reference companies, professional bodies (where you are a member of such bodies), professional regulators, and publicly availably sources such as Companies House, the Electoral Register and any other information in the public domain.
6. Purposes for which we will use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- to contact you to discuss the advice and/or services that you may require, in response to a request from you or referral to you;
- to ask another company connected to the delivery of the AMLCC services to contact you if we feel that is the best way to assist with your enquiry (we will usually notify you in advance of doing so but this is not always possible);
- to carry out our obligations arising from any contracts entered into between you and us, including providing you with access to our products and services;
- to provide you with the information or services that you request from us or which we feel may be of interest you or you may require;
- to ensure that content from our website(s) is presented in the most effective manner for you and for your computer;
- to notify you about changes to our website(s) or the AMLCC platform or the products and services that we offer;
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply with a legal or regulatory obligation, including the prevention of crime.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
|Purpose||Categories of personal data used||Legal basis|
|To respond to your enquiries regarding our products and services.||Identity and Contact Data.||Legitimate interest (in growing our business and developing new customer relationships), prior to entering into any contract with us or as a result of such contract|
|To enable your subscription to our products and services||Identity, Contact, Financial and Transaction Data||Contractual necessity|
|To collect money owed to us||Identity, Contact, Financial and Transaction Data||Contractual necessity and/or legitimate interests (to recover monies due to us)|
|To manage our relationship with you e.g. to keep your details up to date, to respond to your customer care enquiries and support requests and notify you of any changes to our contractual documents or privacy policies||Identity, Contact, Financial and Transaction Data||Contractual necessity and/or legitimate interests (to keep our records updated, provide a high level of customer service and understand how our customers use our goods and services)|
|To send you appropriate marketing communications in accordance with your marketing preferences||Identity, Contact, Transaction, Marketing and Communications, Technical and Usage Data||Legitimate interests (to grow and develop our business). We will however ask for express consent before we share personal data with any third party for marketing purposes|
|To manage and administer our business and website and product (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Transaction, Technical and Usage Data||Legitimate interests (to run our business, provide administration and IT services, ensure network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercises) and/or to comply with our legal obligations|
|To develop and improve our website and AML platform and our customer relationships and experience||Identity, Contact, Transaction, Marketing and Communications, Technical and Usage Data||Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to improve our products and services and to inform our marketing strategy)|
|If you choose to complete a survey that we use for research purposes, or otherwise provide use with feedback||Identity, Contact and/or Transaction Data||Legitimate interests (to understand our customers, develop our business, to improve our products and services and inform our marketing strategy)|
Where we process personal data on the basis of a legitimate interest, as set out in this privacy notice, legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
7. Opting out
You can ask us to stop sending you marketing messages at any time by emailing email@example.com .
8. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out in paragraph 16 below.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9. Disclosures of your personal data
Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other individuals or other entities except in the following circumstances:
- We work with third-party suppliers to help us to serve you better and in some of these cases we may need to share personal data that is necessary to enable those suppliers to perform tasks for us, such as third party payment providers, IT/website/system administration, hosting and support, third-party identity validation and verification services and back-office support.
- Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
- We may share personal data with other companies within the same group of companies, to help us provide products/services to you, or as may be necessary in the context of a business reorganisation or group restructuring exercise. This includes FA Simms and Partners Limited.
- For the purpose of taking advice from our professional advisors, including lawyers, accountants and/or auditors.
- Where we are under a legal duty to do so in order to comply with any legal obligation.
- In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
- If we or substantially all of our assets are acquired by a third party, in which case personal data that we hold about our customers will be one of the transferred assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your personal data when you are on the internet.
11. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ in paragraph 12 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. Your legal rights
You have the right to:
- Request access, to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact Richard Simms using the contact details at the bottom of this privacy notice.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. Your personal data abroad
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
14. Other websites and links
Our website may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third party websites and are not responsible for their privacy notices or for the content, accuracy or opinions express in such websites. We do not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through our website does not imply approval or endorsement by us of the linked website.
15. Changes to this privacy notice
We reserve the right to update this privacy notice at any time. This may be to reflect a change in our products or services, to our internal procedures or to reflect a change in the law.
This privacy notice was last updated in October 2022.
If you have any questions about this privacy notice, please contact Richard Simms.
16. Who to contact
We have appointed Richard Simms to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact Richard Simms by post, email or telephone as follows:
Postal address: AMLCC, Alma Park, Woodway Lane, Claybrooke Parva, Lutterworth, Leicestershire, LE17 5FB
Email address: firstname.lastname@example.org
Telephone: +44 (0)1455 555468.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (see www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.